Privacy Policy and GDPR
The website tobu.be is owned and managed by Let’s Fly. From this point onward, all information below refers to Let’s Fly.
Through the Content Management System used for our website, we receive the following information:
-
Geographical data (country-specific)
-
IP-related data
-
Timestamps
We only use aggregated data and do not make use of your specific personal data. We do not use it for personal purposes or commercial purposes.
When you contact us, we receive your email address, which will be used for correspondence. We use this email address solely for that correspondence.
We undertake to immediately report any data breach involving our systems—such as hacking, theft, or unauthorised access—to the relevant authorities as well as to you, the customer.
If you do not wish us to process your data for direct marketing purposes, simply let us know at info@tobu.be. You may also use this address at any time to request information about the data we process about you, or to have your data corrected or deleted.
If you disagree with the way we process your personal data, you may contact the Belgian Data Protection Authority (Rue de la Presse 35, 1000 Brussels, Belgium).
Our servers are located in third countries and comply with legal obligations under the European Parliament and Council's Standard Contractual Clauses. Additional information can be found here.
WHAT ARE COOKIES, AND HOW ARE THEY USED?
The Internet browser you use to view our site allows a small file called a “cookie” to be saved on your device. This cookie enables our Web server to recognise you as a first-time or repeat client, and may include information such as your log-in information so you do not have to re-enter it every time you visit. We also use cookies to provide customised and personalised services to you.
Your browser does allow you to turn off or warn you about cookies from our site and from any other websites. Cookies do not allow us to know anything about your surfing habits on other websites. They simply tell us about your surfing habits on our website. Let’s Fly may allow certain third parties contracted by Let’s Fly, such as analytics partners, advertising technology partners, and other partners, to use cookies and/or include web beacons on tobu.be web pages for purposes related to those specific partner services. These cookies and web beacons may include your IP address, but do not include any Personally Identifiable Information (“PII”).
NOTE: Tobu.be operates under Belgian law. At this time, no Belgian court has ruled that an IP address is PII. Therefore, as it relates to our data gathering and usage activities and the data gathering and usage activities of our third party partners, Let’s Fly does not consider IP address to be personally identifiable information, as this data is not used in that context. We understand that some entities and individuals outside Belgium do consider IP address to be PII, and we therefore disclose these practices.
HOW DO WE ENSURE THE PROTECTION OF YOUR PERSONAL INFORMATION?
Let’s Fly maintains reasonable physical, electronic, and procedural safeguards to protect the security and integrity of all Personal Information provided to us. Let’s Fly limits access to personal information about you to those employees who we reasonably believe need to come into contact with that information to provide products or services to you in order to do their jobs.
Let’s Fly takes reasonable precautions – including administrative, technical, and physical measures – to safeguard your personal information against loss, theft, and misuse, as well as unauthorised access, disclosure, alteration, and destruction.
HOW LONG WILL YOUR PERSONAL DATA BE RETAINED?
We will retain your personal information for as long as necessary to fulfill and to satisfy any legal, accounting, regulatory, or reporting requirements.
DO NOT TRACK NOTICE AND DISCLOSURE
Let’s Fly does not currently respond to Web browser “do not track” signals and similar signals as providers of these signals do not currently operate according to common, industry accepted standards. However, your browser provides tools to allow you to change your privacy and security settings. For instructions, consult your browser’s Help menu.
For more information on Do Not Track, visit allaboutdnt.com. Let’s Fly will always verify the identity of anyone making a subject access request before handing over any information. In the event Let’s Fly refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
QUESTIONS, CONCERNS AND COMPLAINTS
If you have any questions, concerns, or complaints relating to the processing of your personal data, please send us an email on info@tobu.be. You may raise a complaint with the relevant supervisory authority if you believe Let's Fly infringed applicable data privacy laws when processing your personal data. This right is without prejudice to any other administrative or judicial remedy you might have.
tobu.be and the physical site including the B737-MAX simulator are owned and managed by Let’s Fly.
Registered office:
Aveschoot 69
9971 Lembeke
Belgium
VAT-number: BE0711.655.445
EU GENERAL DATA PROTECTION REGULATION
The EU General Data Protection Regulation (“GDPR”) came into force on 25 May 2018. The new Regulation aims to standardise data protection laws and processing across the EU, giving people greater rights to access and control their personal information.
OUR COMMITMENT
Let’s Fly is committed to ensuring protection of all personal information that we hold, and to provide and to protect all such data. We recognise our obligations in updating and expanding this program to meet the requirements of GDPR. Let’s Fly is dedicated to safeguarding the personal information under our control and in maintaining a system that meets our obligations under the new regulations. Our practice is summarised below.
HOW WE PREPARED FOR GDPR
Let’s Fly already has a consistent level of data protection and security, with following Policies and Procedures. We have data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
-
Data Protection - our main policy and procedure document for data protection to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy and the rights of individuals.
-
Data Retention and Erasure - to ensure that we meet the "data minimisation" and "storage limitation" principles and that personal information is stored, archived and destroyed in accordance with our obligations.
-
Data Breaches - our procedures ensure that we have safeguards in place to identify, assess, investigate and report any personal data breach as early as possible.
-
International Data Transfers and Third-Party Disclosures - where Let’s Fly stores or transfers personal information outside the EU, we have robust procedures in place to secure the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as binding rules, or standard data protection clauses for those countries without.
-
Privacy Notice/Policy - to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
-
Obtaining Consent - we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information.
DATA SUBJECT RIGHTS
Access to individual’s rights with regards to any personal information that Let’s Fly processes about them and to request information about can be acquired via an email to us here. What personal data we hold about them. How long we intend to store your personal data for. The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this. The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use. The right to lodge a complaint or seek judicial remedy and who to contact in such instances.
INFORMATION SECURITY, TECHNICAL AND ORGANISATIONAL MEASURES
Let’s Fly takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure to protect and secure the personal data that we process.
